Urgency to update Germany’s coal mine methane emission factor

This report by Ember argues that Germany significantly underreports methane emissions from its coal mining sector due to an outdated and unverified single emission factor from 1989. The analysis suggests that actual emissions could be 28 to 220 times higher than official figures, urging an urgent update to monitoring, reporting, and verification (MRV) frameworks ahead of the new EU Methane Regulation.

• Germany's reported coal mine methane (CMM) emissions are likely a severe underestimation. In 2022, Germany produced 44% of the EU's total lignite but reported active CMM emissions of only 1.39 thousand tonnes, which is 1% of the EU's reported active surface CMM emissions from 2021.
• Independent estimates indicate that Germany's actual CMM emissions from active mining operations are between 28 and 220 times higher than official government reports. The highest estimate, provided by Global Energy Monitor (GEM), suggests an additional 300,000 tonnes of methane emissions annually.
• Germany relies on a single emission factor based on a 1989 study by Rheinbraun AG, which is considered inadequate because it does not account for variability in mine location, depth, or changes in coal seam permeability. This factor is estimated to be 40 to 100 times lower than measurements of Polish lignite, despite Germany considering its coal comparable to Poland's.
• The current German emission factor is based only on samples from the Rhine basin and may not represent the entire country. Furthermore, it fails to account for methane emissions from surrounding strata (over- and under-burden), a requirement noted in IPCC guidelines and practiced by the U.S. Environmental Protection Agency.
• Ember's own estimate, using the Model for Calculating Coal Mine Methane (MC2M) and data from Polish lignite samples, places Germany's annual CMM emissions at approximately 256,000 tonnes.
• The upcoming EU Methane Regulation will mandate the use of "deposit-specific coal mine methane emission factor" established on a quarterly basis, which must include emissions from surrounding strata. This creates a regulatory necessity for Germany to overhaul its current MRV methodology.
• Ember recommends three primary actions for Germany: implementing direct measurement and modeling of emissions (including for closed mines), avoiding further coal mine expansions while phasing out the gassiest mines first, and requiring methane mitigation such as pre-mine drainage.

APA

Assan, D. S. (2024). Urgency to update Germany’s coal mine methane emission factor. Ember. https://ember-energy.org/app/uploads/2024/04/Urgency-to-update-methane-emission-factors-from-Germanys-coal-mining-sector-2.pdf

Chicago

Assan, Dr. Sabina. Urgency to update Germany’s coal mine methane emission factor. Ember, 2024. https://ember-energy.org/app/uploads/2024/04/Urgency-to-update-methane-emission-factors-from-Germanys-coal-mining-sector-2.pdf.

Wikipedia

{{cite report |last1=Assan |first1=Dr. Sabina |title=Urgency to update Germany’s coal mine methane emission factor |publisher=Ember |date=10 April 2024 |url=https://ember-energy.org/app/uploads/2024/04/Urgency-to-update-methane-emission-factors-from-Germanys-coal-mining-sector-2.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{assan2024urgency, author = {Assan, Dr. Sabina}, title = {{Urgency to update Germany’s coal mine methane emission factor}}, institution = {Ember}, year = {2024}, month = apr, url = {https://ember-energy.org/app/uploads/2024/04/Urgency-to-update-methane-emission-factors-from-Germanys-coal-mining-sector-2.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }